Piazza v. Cuyahoga Cnty., 2017 Ohio 8163

Marcella King Piazza worked for Cuyahoga County (various offices) and was terminated on March 9, 2011 alongside two other former board-of-revision employees.
Within 90 minutes of her discharge a Plain Dealer reporter called Piazza; about 20 minutes later the Plain Dealer published an article reporting the firings and tying them to a board-of-revision scandal; a second article that day repeated statements by County Executive FitzGerald and included a county‑provided photograph of Piazza.
Piazza sued the county and the Plain Dealer in 2015, alleging false light invasion of privacy and claiming FitzGerald’s quoted statements were made with reckless disregard for truth.
The county moved for summary judgment asserting political‑subdivision immunity under R.C. Chapter 2744 and that the claim was time‑barred; the trial court denied summary judgment, finding genuine issues of material fact and that immunity did not apply because the claim arose out of the employment relationship.
On appeal the county challenged the denial of immunity and the statute‑of‑limitations ruling; the appellate court addressed immunity but held it lacked jurisdiction to review the statute‑of‑limitations ruling as a separate ground for denying summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2744.09(B) bars political‑subdivision immunity for an intentional tort (false light) that "arises out of the employment relationship" when the plaintiff was terminated before the tortious statements were made	Piazza: Her false light claim is employment‑related because the statements were made within hours of her termination, concerned her job/performance, and thus "arose out of the employment relationship" so immunity does not apply	County: Piazza was not an employee when she filed suit and the statements occurred after her termination, so the R.C. 2744.09(B) exception does not apply and immunity remains	The court held R.C. 2744.09(B) covers claims that arise out of the employment relationship even when asserted by former employees whose alleged injury is connected to their employment; immunity did not apply (assignments 1–4 overruled)
Whether the appellate court may review the county's statute‑of‑limitations defense raised on summary judgment	County: The denial of summary judgment on statute‑of‑limitations grounds was erroneous	Piazza: No special argument on appeal; trial court found claim not time‑barred	The appellate court concluded it lacked jurisdiction to review the statute‑of‑limitations denial because R.C. 2744.02(C) permits appeal only from orders denying immunity; the statute‑of‑limitations challenge was dismissed for lack of jurisdiction

Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (summary judgment standard)
Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 (summary judgment standards on construing evidence for nonmoving party)
Dresher v. Burt, 75 Ohio St.3d 280 (moving party’s burden in summary judgment)
Elston v. Howland Local Schools, 113 Ohio St.3d 314 (three‑step governmental immunity analysis under R.C. 2744)
Brady v. Safety‑Kleen Corp., 61 Ohio St.3d 624 (intentional torts and employment scope)
Sampson v. Cuyahoga Metro. Hous. Auth., 131 Ohio St.3d 418 (R.C. 2744.09(B) can encompass employer intentional torts arising from employment relationship)
Riscatti v. Prime Props. Ltd. Partnership, 137 Ohio St.3d 123 (limits on appealability of non‑immunity grounds when immunity denial is appealed)